Comments submitted to the Federal Communications Commission (FCC) by the American Cable Association (ACA) regarding that agency’s competitive-bidding process to disburse Universal Service Fund (USF) support generally favor the plan but they encourage the commission to pay particular attention to census-block information.

Census blocks are the smallest geographic area for which the Bureau of the Census collects and tabulates decennial census data. They are formed by streets, roads, railroads, streams and other bodies of water; by other visible physical and cultural features; and by the legal boundaries shown on Census Bureau maps (click here for more information).

ACA provided the FCC with the following recommendations to help ensure an effective auction process:
 
>> Support should be provided to a single recipient that bids to receive the least amount of support to provide broadband service meeting the public-interest obligations in the eligible service area.
>> Areas that are eligible to receive support should be based on census blocks.
>> Census blocks eligible for support are those with costs for broadband service as determined by the forward-looking broadband cost model that are sufficiently higher the national average but are not “extremely” high-cost, and where an unsupported provider doesn’t offer 4 Mbps/1 Mbps broadband service to at least a majority of locations.
>> The public must be given the opportunity prior to the auction to comment on and challenge the determination of whether a census block is served by an unsupported competitor.
>> An auction’s reserve price for an area should be based on a forward-looking cost model in combination with evidence from prior auctions.
>> Auction participants should submit bids to provide service to all eligible high-cost census blocks in a census tract, and winners should be chosen on a census-tract basis.
>> Support should be provided for a five-year term with no right to renewal, and the FCC should re-evaluate the need for support and the method of support after that time.
>> The FCC should hold sequential regional auctions, and bidding in each region should occur over multiple rounds until a clear, lowest bid is provided.
>> Support should be awarded only if an auction is fully competitive, which can be determined by examining the degree by which the winning bid varies from winning bids in similarly situated areas.
>> Recipients of support should provide broadband service meeting the public-interest commitments designated by the FCC to at least 95 percent of locations in the service area (census tract) within two years.
 
Notes ACA President/CEO Matthew M. Polka, “The FCC has proposed a viable competitive bidding process to disburse Universal Service Fund support to ensure that the urban-rural digital divide quickly becomes a distant memory. By adopting several ACA policy recommendations, the FCC will further ensure that funding flows in the most efficient fashion to the low-cost providers meeting minimum performance standards.”

To read the comments in their entirety, click here.

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